Executive summary

The EUDR prohibits placing on the European Union market, making available on that market or exporting from it seven commodities — cattle, cocoa, coffee, oil palm, rubber, soy and wood — and a closed list of derived products, unless they meet three conditions cumulatively: they are deforestation-free (produced on land not deforested after 31 December 2020), they are legal under the legislation of the country of production, and they are covered by a due diligence statement (or, for micro and small primary producers in low-risk countries, by a simplified statement).

In one sentence: from 30 December 2026, no soybean, meal or oil enters the EU unless the European importer can demonstrate, with the geolocation of every plot of origin, that the area was not deforested after 2020 and that production was legal.

The ten points any manager needs to know

1. Dates of application. Large and medium-sized companies: 30/12/2026. Micro and small companies established up to 31/12/2024: 30/06/2027 (Article 38, following Regulation (EU) 2025/2650).
2. An absolute cut-off date. 31/12/2020. Deforestation after that date — legal or illegal, human-caused or natural, followed by agricultural use — makes the area and everything coming out of it non-compliant.
3. Traceability down to the plot. Geolocation of every plot of origin, to six decimal places; a polygon is mandatory for areas above 4 hectares (except for cattle).
4. Mass balance is prohibited. Compliant product may not be mixed with product of unknown origin at any stage. Physical segregation is mandatory; full identity preservation is not.
5. Who is liable. The "operator" — whoever first places the product on the EU market or exports it. In the Brazilian soy chain that is typically the European importer. The Brazilian exporter has no direct legal obligation, but will not sell without handing over the data.
6. Three steps of due diligence. Information gathering (Article 9), risk assessment (Article 10) and risk mitigation (Article 11), within a system reviewed at least once a year (Article 12).
7. Brazil is "standard risk". Under Implementing Regulation (EU) 2025/1093, Brazil is on neither the low-risk nor the high-risk list. The consequence: full due diligence by the importer, and checks on a minimum of 3% of operators per commodity.
8. Legality is broadly defined. "Relevant legislation" covers eight areas: land use rights, environmental protection, forest-related rules, third parties' rights, labour rights, human rights, the free, prior and informed consent of indigenous peoples, and tax, anti-corruption, trade and customs rules — always as they relate to the legal status of the area of production.
9. Heavy penalties. Fines with a maximum of at least 4% of annual EU turnover, confiscation of products and of revenue, exclusion from public procurement for up to 12 months, and a temporary ban on trading.
10. The regime became simpler, not softer. The 2025 amendments removed downstream due diligence and created the simplified statement, but left the cut-off date, geolocation, legality and the ban on mass balance untouched. In May 2026 the Commission stated that it will propose no further amendments to the basic text.

Structure of the report